MiFID compliant charges and review docs

ruthiebusybee

Hi All

Now that the tax year is over, we're turning our attention to polishing our MiFID review documents.

Has anyone got any more examples that they'd be happy to share? I've got a copy of the Dynamic Planner one that was shared on a previous thread.

Thanks

edevan5

Hi,

We’ve recently revamped our review report and I’ve attached an example report for you to have a look at. Although the new MiFID II reporting requirements were one of the main drivers for the revamp, we were also keen to try to design a process / report that would:

1. help our users to demonstrate the value of their service to their clients;
2. provide the client with a more holistic review of their financial affairs; and
3. streamline the review process.

As you’ll see the report can include:

• An update on the client's circumstances.
• An update on the client's assets and liabilities.
• A review of the client's attitude to risk.
• A detailed review of the client's objectives.
• A summary of the key outputs / outcomes following a review of the client's cash flow plan.
• A review of the client's existing plans with recommendations to retain, top-up, withdraw an income / lump sum or switch funds.
• Ex-ante and / or ex-post charges disclosure in line with MiFID II reporting requirements.
• A review of your service so you can demonstrate the value you have provided to the client over the past twelve months / since your last review.
• Any next steps and action required by you or the client.
• An authority to proceed.
• Relevant product and technical notes in the appendix.

Anyway, hope that helps; and if anyone’s got any comments or suggestions, we’d love to hear them.

Thanks,

Ed

Hnew

Hi

I am interetsed in your thread as our workload had increased dramatically since we started doing periodic suitability assessment reports towards the end of the summer. It is not so much the letter but the whole process. I can help but think there has got to be a better way - and by that I mean more efficient.

We arent disclosing costs and charges in our reports as these are being send out directly by platforms to clients. I am honestly not sure what to do about investments such as VCT/EIS/ITS.

We are on IO and Threesixty members.

Thanks

Hannah

Rebecca_Tuck

Hi @edevan5

I might be missing something (it's been a long day), but how are the reduction in yield figures calculated in your example (page 13)? I'd have expected the RIY figures to be higher than the ongoing charges to include any lost growth etc. as a result of the fees taken?

edevan5

Hi @Rebecca_Tuck

The figures within the report have only been added as examples and clearly don't stand up to close scrutiny!

Sorry, didn't mean to mislead. There is no fancy calculations going on here (yet) in terms of ex-post charges disclosure. The idea is that the charges figures can be transposed from another source and displayed within the report should you wish to include them.

As an alternative you could opt to include a statement signposting the reader to a separate cost and charges disclosure statement.

ruthiebusybee

@Hnew I'm not sure we're okay to rely just on what providers are sending out - they aren't yet issuing them, the only one we've had so far is from Blackfinch, and we were told off by our external compliance for not having been issuing these reports manually ourselves already, we were told it's not enough to rest back on the providers' extension, advisers were afforded the same extension.

Happy to get wider comment on this view........any one already routinely issuing full MiFID reports for the last 6 ish months as dictated?

Nath

Ed, I appreciate your review report contains some recommendations so will always be lengthier where no changes have been made but it does seem heavy on content/number of pages for a planning meeting/review.

We have a meeting agenda where all the specifics and detailed notes are taken regarding the planning meeting and then provide the client with a one page summary showing bullet points for immediate/long term objectives, key discussions, and any next steps. If advice is given off back of review then normal suitability report etc but where no advice always kept to one page max (maybe double sided to include MiFID/charges disclosure but that's it. We found clients just did not read a lengthy planning meeting summary.

As a caveat we do also save a snapshot of the Voyant outputs/cashflow and any scenarios which is also uploaded to the client wealth platform login, but I appreciate you sharing this example especially from the MiFID II perspective.

edevan5

Thanks for the feedback @Nath and appreciate what you're saying. There is clearly no 'one size fits all' approach to this and I guess when the example report was created we were just trying to showcase everything that could be achieved However, being a modular report builder you can choose to include as much or as little as you want...

Nath

Totally understood Ed...from a template perspective best to have the lot in there and then reduce as needed.

charlotte.e

How is everyone getting on with Mifid II? I'm feeling rather overwhelmed by it all and interested to know how are other firms managing this? thanks!

charlotte.e

Connected to my comment above we have noticed that some of the investment managers are not including the investment management costs (the TER) in their aggregated costs and charges statements (just the annual management fee).

We use Intelligent Office (IO) and they have an ‘aggregated costs and charges’ report which can be pulled off the system. This includes investment transaction fees but again, it doesn’t account for TER of funds or investments. Assuming this is all accounted for within the unit price.....

Based on the information above, am I missing something or does the TER still need to be included in the aggregated cost in our fees and charges report to clients?

arongunningham

I don't know what we're calling MIFID compliant charges... is it still a TER, or an AMC, or an OCF??

Whatever we're calling them, you need to calculate and include the total cost to the client and illustrate this on a per 'cost-type' level and at an aggregated level.

This includes all transaction charges, other duties/levies, adviser charges, product charges, investment charges... everything!

I have built a spreadsheet to help automate this to some extent, but there's no shortcut in collating the information in the first place. We have taken a view that transaction charges are on average 0.20% and therefore we can just take the TER and another line to the table for 'transactions'.

I don't use platforms, but you'd assume that illustrations will do some of this work for you now? Or are they generally still behind with their technology.

charlotte.e

Thanks @arongunningham